125 Datapoints, 9 Categories — Where to Begin
A fully compliant textile Digital Product Passport is not a simple product information sheet. The most comprehensive textile-specific DPP data protocol developed to date covers nine data categories and more than 125 individual datapoints. For most brands, this number is immediately overwhelming.
It does not need to be. The 125 datapoints span a wide range — from straightforward facts you almost certainly already hold (your brand name, the country where your garment was made) to complex methodology-dependent calculations (product environmental footprint) that the EU has not yet fully standardized.
The practical approach is to understand what each category requires, assess what you currently have, and build your data collection roadmap systematically — starting with the datapoints that are clear and obtainable today.
This guide walks through all nine categories, what they contain, where the data comes from, and what is still awaiting regulatory clarification.
Category 1: Brand Information
What it covers: The identity of the entity responsible for the product — the brand name as it appears on the label, any parent company or group structure relevant to compliance, and the brand's unique operator identifier.
Key datapoints:
- Primary brand name
- Brand unique operator identifier
- Importer information (if different from brand)
- Responsible Economic Operator (REO) details
Where it comes from: Your internal commercial and legal records. This is among the simplest category to populate — the data exists and is unambiguous.
Status: Ready to collect now.
Category 2: Supply Chain Information
What it covers: The facilities and suppliers involved in producing the product — from the final assembly stage back through the supply chain to raw material processing. This is the traceability backbone of the DPP.
Key datapoints:
- Tier 1 supplier name and facility identifier (cut, make, trim)
- Tier 2 supplier names and identifiers (fabric mills, dyehouses, finishing)
- Tier 3 and beyond — spinners, yarn producers (where available)
- Geographic location of each facility (country, city)
- Unique facility identifiers (where standardized identifiers are in use)
- Manufacturing processes performed at each stage
Where it comes from: Your supplier management systems, purchase order records, and — critically — the suppliers themselves. Tier 2 and Tier 3 data is typically the most difficult to obtain, requiring active supplier engagement programs.
What makes this challenging: Most brands have good visibility of their Tier 1 suppliers but limited data on Tier 2 (fabric mills, dyehouses) and almost no systematic data on Tier 3 (spinners, fibre processors). Building this visibility is the core work of supply chain traceability — and it is also the foundation that makes DPP data collection significantly faster and more accurate.
Status: Partially available for most brands. Tier 2+ data requires active traceability investment.
Category 3: Product Information
What it covers: The core identity data for the specific product — not the brand, not the supplier, but this particular SKU or style.
Key datapoints:
- Product identification system used (GTIN, SKU, style number)
- Serialized unique product identifier (per individual unit)
- TARIC commodity code
- Product category and type description
- Season of intended sale
- Target market(s)
Where it comes from: Your PLM (Product Lifecycle Management) system, ERP, and product development records. The GTIN is typically already assigned for retail products. The serialized GTIN — unique to each individual unit — may require new processes if you are not currently generating serial numbers at the unit level.
Important distinction: A GTIN identifies a product model. A serialized GTIN identifies a specific individual garment. A production run of 500 identical garments requires 500 different serialized GTINs. This is the identifier layer discussed in our DPP Three-Layer Architecture post.
Status: GTIN data ready now. Serialization infrastructure may require new processes.
Category 4: Material Information
What it covers: The detailed fibre and material composition of every component of the product — not just the overall garment, but each individual component: the body fabric, lining, trim, thread, buttons, zips, and any other material element.
Key datapoints:
- Component-by-component fibre breakdown (body, lining, collar, cuffs, trim, etc.)
- Fibre type and percentage for each component (must total 100% per component)
- Recycled content percentage and certification
- Country of origin of primary raw materials
- Relevant material certifications (GOTS, GRS, OEKO-TEX, etc.)
- Presence of animal-derived materials
Where it comes from: Your product specifications, BOM (Bill of Materials) documents, and material test reports. Recycled content claims require supporting certification documentation — not just a supplier declaration.
What makes this challenging: Most brands know their overall garment composition (as required by the EU Textile Labelling Regulation) but often do not have component-level breakdowns. The lining composition, the thread type, the interlining — these are frequently missing from standard product records. Obtaining them requires detailed supplier engagement at the fabric and trim level.
Status: Overall composition data typically available. Component-level breakdown frequently requires additional data collection.
Category 5: Digital Identifier
What it covers: Information about the physical data carrier attached to the product — the mechanism through which the DPP is accessed.
Key datapoints:
- Type of data carrier used (QR code, RFID, NFC, watermark)
- Data carrier standard and format
- Location of data carrier on product
- Resolver endpoint associated with the identifier
Where it comes from: Your DPP platform and label specification decisions. This category is generated through your DPP implementation process rather than collected from suppliers.
Status: Determined by your DPP system setup. Ready to configure once platform and label supplier decisions are made.
Category 6: Care Information
What it covers: All instructions for maintaining the product correctly throughout its use phase — the information that extends product lifespan when followed correctly.
Key datapoints:
- Washing instructions (temperature, cycle type, hand wash only, etc.)
- Drying instructions (tumble dry settings, line dry, flat dry)
- Ironing instructions (temperature settings, steam)
- Dry cleaning suitability
- Bleaching instructions
- Care symbol images (ISO 3758 care labelling standard)
- Special care considerations (delicate materials, structured garments)
Where it comes from: Your product development and quality team. Care instructions are already required on EU garment labels under the EU Textile Labelling Regulation — for DPP purposes, this data simply needs to be provided in digital, structured format as well.
Good news: This is one of the categories where you almost certainly already have all the data. It is a matter of formatting and digitizing what already exists on your physical labels.
Status: Ready to collect and structure now. Low effort, high confidence.
Category 7: Compliance Information
What it covers: Documentation and declarations related to chemical safety, regulatory compliance, and any substances that must be disclosed under EU law.
Key datapoints:
- Presence or absence of substances of concern (SVHC under REACH)
- If present: name of substance and concentration level (disclosure required above 0.1% by weight)
- Declaration of conformity
- Technical documentation references
- Conformity certificates
- Voluntary EU Ecolabel status
- Test reports relevant to regulatory compliance
Where it comes from: Your existing REACH compliance documentation, chemical test reports from accredited laboratories, and conformity declarations. Brands that already manage REACH compliance systematically will have much of this data — the DPP requires it to be linked to the specific product and accessible digitally.
Important: Substance of concern disclosure in the DPP is aligned with existing REACH obligations. If a substance is present above the threshold, it must be named and disclosed. This is not a new requirement — it is an existing one that must now be surfaced through the DPP data layer.
Status: Available for brands with systematic REACH compliance programs. Requires structured digitization and product-level linkage.
Category 8: Circularity Information
What it covers: Data that enables the product to participate in circular economy pathways — repair, reuse, remanufacturing, and recycling. This is the category most directly connected to the DPP's core purpose.
Key datapoints (many still being standardized):
- Recyclability potential and instructions
- Disassembly instructions for treatment facilities
- Reparability information — availability of spare parts, repair instructions
- Durability and expected lifespan data
- Presence of components that inhibit recycling (coatings, bonded elements, mixed fibre constructions)
- Recommended end-of-life pathway
- Take-back or collection point information (where available)
- Circularity performance metrics
Where it comes from: A combination of product development knowledge (your design team knows whether a garment was designed for disassembly), supplier technical data, and — where available — laboratory assessments of recyclability.
What is still unclear: The precise metrics for measuring and communicating circularity performance are not yet standardized. How "recyclability" is defined and measured, how durability is quantified, and how these are expressed in a DPP context are all subject to ongoing EU standardization work. This is a category where you can begin documenting qualitative information now while awaiting quantitative methodology guidance.
Status: Partially available. Qualitative data collectable now. Quantitative metrics awaiting standardization.
Category 9: Sustainability Information
What it covers: Brand-level and product-level sustainability context — certifications, environmental performance data, and sustainability commitments relevant to this product.
Key datapoints (with significant methodology caveats):
- Product-level environmental footprint (carbon, water, energy — methodology still being standardized)
- Sustainability certifications held for this product or its materials
- Brand sustainability statements relevant to this product (governed by the Green Claims Directive)
- Social compliance information
- Traceability depth and verification level
The Green Claims challenge: This category sits at the intersection of DPP requirements and the EU Green Claims Directive — which requires that any environmental claim made to consumers must be substantiated by verifiable evidence. For brands that want to include product carbon footprint data in their DPP consumer interface, the methodology for calculating that footprint must be standardized, documented, and defensible.
The Product Environmental Footprint (PEF) methodology, which the EU is developing as the standard approach, is not yet finalized for textiles. This creates a difficult position: brands may have footprint data, but publishing it through the DPP carries legal risk if the methodology used does not align with what the Delegated Acts ultimately require.
The practical approach is to collect and document the underlying data now (energy consumption, water use, transport data) using existing LCA methodologies, while waiting for PEF finalization before making public-facing footprint claims.
Status: Certifications and qualitative statements collectable now. Footprint calculations require methodology clarity before public disclosure.
The Critical Distinction: Objective vs Methodology-Dependent Datapoints
Across all nine categories, the datapoints fall into two fundamentally different types — and recognizing this distinction prevents the most common mistake brands make when approaching DPP preparation:
- Objective "direct" datapoints — facts that are knowable and unambiguous right now. Country of manufacture, fibre composition, supplier name, care instructions, REACH compliance status. These datapoints do not require any EU methodology decision to be collected. Start now.
- Methodology-dependent datapoints — datapoints whose value depends on a calculation methodology that is still being standardized at the EU level. Carbon footprint, recyclability score, durability rating. These cannot be responsibly published to consumers until the relevant standards are confirmed — but the underlying data that will feed these calculations should be collected and documented in the meantime.
The absence of clarity on methodology-dependent datapoints is not a reason to pause DPP preparation. The objective datapoints are ready to collect today, they represent the majority of the initial DPP data requirement, and they are the foundation on which the methodology-dependent datapoints will eventually sit.
Building Your Data Collection Roadmap
- Audit what you have: Use the DPP Data Checklist to map your current holdings against all nine categories
- Prioritize the objective datapoints: Categories 1, 3, 6, and portions of 2, 4, and 7 are largely collectable today
- Engage your suppliers: Category 2 (supply chain) and Category 4 (material composition at component level) require structured supplier data requests — see the Supply Chain DPP Preparation Guide
- Document methodology-dependent data separately: Collect the raw inputs for footprint calculations without committing to specific output values until methodology standards are confirmed
- Assess your system gaps: Take the DPP Readiness Assessment to understand where your data infrastructure needs investment
Frequently Asked Questions
Does a brand need to complete all 125 datapoints before its DPP is valid?
Not necessarily all 125 — the precise mandatory fields will be defined in the Delegated Acts for textiles. Some datapoints are mandatory, others are optional or conditional. Brands that engaged in live DPP pilots found that focusing on the most critical and available datapoints first — while maintaining a flexible data structure for future additions — was the most practical approach.
Can the same DPP data protocol be used for different product types?
The nine-category structure applies broadly to textile products, but specific datapoints vary by product type. A structured jacket has different circularity and disassembly data than a knitted t-shirt. The protocol should be treated as a framework that is adapted for each product category within your range.
What happens if a brand cannot obtain Tier 2 or Tier 3 supplier data?
This is one of the most common data gaps in DPP preparation. Where primary data from suppliers is unavailable, proxy data or industry-average figures may be used for initial assessments — but these cannot support specific product-level claims. Building supplier relationships that enable direct data sharing is a medium-term investment that pays dividends across multiple regulatory requirements beyond DPP.
Ready to start your DPP journey?
Talk to our team about preparing your textile products for EU Digital Product Passport requirements.